NGS 48 DATA PROTECTION 48 CERTAIN BRITISH VIRGIN ISLANDS TAXATION CONSIDERATIONS 49 CERTAIN CAYMAN ISLANDS TAXATION CONSIDERATIONS 51 CERTAIN UNITED STATES FEDERAL INCOME TAX CONSIDERATIONS FOR U.S. HOLDERS 53 RISK FACTORS 56 RESALE AND TRANSFER RESTRICTIONS 75 NOTICE TO PURCHASERS 76 TO PURCHASERS GENERALLY 78 EXHIBIT A - FORM

THE ADMINISTRATOR 18 NET ASSET VALUE 19 LEGAL PROCEEDINGS 20 DATA PROTECTION 20 CERTAIN CAYMAN ISLANDS TAXATION CONSIDERATIONS 21 CERTAIN UNITED STATES FEDERAL INCOME TAX CONSIDERATIONS 23 RISK FACTORS 29 REGULATION 39 ANTI-MONEY LAUNDERING AND ANTI-TERRORIST FINANCING PROCEDURES 40 NOTICE TO PURCHASERS 42 WEST1282936389.4

elieves to be reliable, but The Bank of New York Mellon Corporation takes no responsibility for the accuracy thereof. S-29 EFTA00597138 MATERIAL UNITED STATES FEDERAL INCOME TAX CONSIDERATIONS This section describes the material United States federal income tax consequences relevant to the purchase, ownership and disposition of the Series

also will be given by mail to the addresses of the holders as they appear on the security register. S-28 EFTA00601731 Table of Contents CERTAIN UNITED STATES FEDERAL INCOME TAX CONSIDERATIONS The following is a summary of certain United States federal tax consequences of the purchase. ownership and disposition of depositary shares repres

nts will be listed separately and as a unit on NASDAQ. We cannot guarantee that ow securities will be approved for listing on NASDAQ. 131 CERTAIN UNITED STATES FEDERAL INCOME TAX CONSIDERATIONS The following is a discussion of the material U.S. federal income tax consequences of the acquisition, ownership and disposition of our units, shar